Looking Forward

Abstract This chapter considers the future of international sanctions amid declining multilateralism following the 2022 Russian invasion of Ukraine. It argues that U.S. unilateralism—underpinned by the International Emergency Economic Powers Act (IEEPA)—will remain dominant, reinforced by the dollar’s primacy and executive authority via Executive Orders. The 2025 reimposition of ICC sanctions through EO 14203, targeting Prosecutor Karim Khan, exemplifies this unilateral approach. Russia and Iran have endured protracted and extensive western sanctions with little impact and so the prospects for coordinated sanctions on China or Iran are limited by doubts over whether they will effect a change in behaviour. China’s significant economic strength and countermeasure capability further constrain unity. The chapter considers US judicial developments, notably Loper Bright (2024) ending ‘Chevron deference’ leading to greater scrutiny of OFAC decisions, as illustrated by Tornado Cash. Looking forward, while bilateral co-operation (e.g., OFAC–OFSI, OFAC–SECO) continues, multilateral coordination is unlikely, leaving U.S. policy foreign as a primary influence on sanctions regimes.